A major fault of the creation of a Consumer Financial Protection Agency is the resulting loss of reconciliation between prudential and consumer regulation of financial services firms. What might be prudential — for example, a hold on checks in order to avoid fraudulent transactions — might be anti-consumer — i.e., it forces consumers to wait longer than technologically necessary to have their money available for use. There are many such examples, and under current law the problem is worked out within each prudential regulator.

Similarly, HUD has now issued regulations concerning the scope and use of Good Faith Estimates and the HUD-1, and those regulations will go into effect on Jan. 1.

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